Develop a retention strategy for its subrecipients to ensure that documentation is readily available for review.

Repay the Housing Choice Voucher program from non-Federal funds the $281,929 in ineligible retroactive housing assistance payments.

Develop and implement internal control procedures to ensure that housing assistance funds appropriated for 1 calendar year are not used to make retroactive housing assistance payments for prior years.

Repay the Housing Choice Voucher program from non-Federal funds the $32,682 in ineligible housing assistance overpayments made due to program errors.

Develop and implement internal control procedures to ensure that housing assistance payments resulting from errors of Authority officials are covered by the Authority’s administrative fees.

Develop and implement internal control procedures to ensure that housing assistance payments are not made to owners without a properly executed lease and housing assistance payments contract.

Develop and implement internal controls to ensure that housing assistance payments discontinue once a program participant is absorbed into another public housing agency’s program or leaves the program.

Provide support showing that the repayment of housing assistance overpayments found by the Authority were received.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $11,463,971 in 189 program obligations and $13,640 in 10 administrative obligations marked for deobligation as of September 30, 2017.

Review the 1,110 identified inactive retained obligations with remaining balances totaling $229,327,332 and close out and deobligate amounts tied to obligations that are no longer valid or needed.

Close out and deobligate the remaining balances on 2,741 expired homeless assistance contracts of $159,437,069.

Work with OCFO to develop a consistent and reasonable methodology for determining the PIH prepayment, which (1) allows for timely recording of financial events, (2) complies with GAAP, and (3) provides an adequate audit trail until the cash management process is automated.

Reopen recommendation 2016-FO-0003-002-D, “Develop a tracking function for the payments advanced to IHBG recipients to facilitate financial reporting and monitoring compliance with grant time restrictions.”

Review the one identified retained inactive obligation with a remaining balance totaling $765,000 and close out and deobligate amounts tied to obligations that are no longer valid or needed.

For all 32 debts not under repayment agreement, (1) send demand letters for any debts for which a demand letter has not been sent and (2) aggressively work with the PHAs to determine appropriate repayment agreement terms.

Establish procedures to ensure that the debt file is sent to the OCFO DCCO for claim establishment if initial collection attempts prove unsuccessful.

Establish procedures to routinely send all debts (delinquent or not) to OCFO for evaluation as required by the debt collection handbook.

Finalize the repayment agreement procedures and implement training to ensure that all of PIH is aware of the procedures. The repayment agreement procedures should ensure that PIH follows HUD’s debt collection handbook.

We recommend that the Deputy Assistant Secretary for Public Housing and Voucher Program follow departmental clearance procedures and issue clarification to public housing agencies to explain what is being certified to in the Application.

We recommend that the Deputy Assistant Secretary for Public Housing and Voucher Programs require public housing agencies to sign the certifications on form HUD-52723 or remove the certification.